MEMORANDUM BY SURREY COUNTY COUNCIL (DSW
92)
1. GENERAL
Surrey County Council is at the forefront of
local authority waste management contracting having been awarded
Private Finance Initiative funding of £100m for its integrated
waste management contract awarded in 1999. The contract is for
one billion pounds over 25 years. It was conceived in a context
of joint working between two-tier waste authorities and recognises
that only by integrating the contribution of the private sector
within a local authority partnership framework will any real progress
be made towards achieving sustainable waste management.
The structure of the contract recognises and
gives effect to the realisation that only through the use of incineration,
whether combined heat and power or energy recovery, will the diversion
rates from landfill, which will be a legally binding obligation
on the UK, be achieved. It recognises that a balance between waste
management options has to be struck in order to obtain the political
and public support that is needed in order to avoid virtual total
reliance on incineration as the only practical waste management
option.
The contract was conceived within the framework
of a Way With Waste. In its last report on waste management, the
committee noted that "waste management in this country is
still characterised by inertia, careless administration, and ad
hoc, rather than science based, decisions." The lessons from
this contract, which is less than one year into its term, indicate
that possibly inertia is a safer attitude than action when one
is dealing with an administration in the government which has
by its action demonstrated so little regard for the actual realities
which confront local authorities.
As a consequence of letting its contract to
one of the largest waste management companies in Europe, and also
one of the largest landfill operators on the UK, Surrey has conceived
a singular relationship with the contractor's landfill tax Environmental
Trust. Current planned disbursements within Surrey are approx
£1 million per annum with at least 60 per cent earmarked
for sustainable waste management purposes.
The committee's investigation is under the title
Delivering Sustainable Waste Management. In addition to the general
questions being addressed, the committee has identified several
particular issues that it wishes to examine. This evidence will
focus on those issues as they affect Surrey and the management
of the household waste stream. It will attempt to draw more general
conclusions where it is felt safe to do so.
2. EVIDENCE
2.1 This will be addressed against the following
specific context.
(a) The EU Council of Ministers have approved
the landfill directive which the UK government has indicated that
it will bring into effect by July 2001. It has stated that it
will apply the four year derogation options.
(b) Government has stated that it sees the
relationships between the two-tier authorities as a reason for
poor progress towards the previous recycling targets which were
set out in Making Waste Work.
(c) Government has indicated a national
average increase in waste per annum in the region of three per
cent and should therefore be able to utilise this with its data
from the household waste survey to calculate future supply of
recyclable materials when applied to its prescribed recycling
targets.
(d) The government has recently published
its proposals for setting targets etc. in its review of Best Value
2001/2002. These are taken to be actual, rather than aspirational,
targets which was an issue upon which the committee focused in
its last report.
(e) Surrey County Council in partnership
with SITA Environmental Trust and the University of Surrey Environmental
Body is participating in one of the largest issue-specific public
attitude surveys into waste and residents' behavioural drivers
undertaken.
(f) A land use planning framework which
has each shire county determining its own waste land use policies.
2.2 More efficient use of resources and consequent
reduction in the amount of waste entering the waste stream
The precise thrust of this issue is a little
unclear. Clearly manufacturers can obtain improved materials efficiencies,
however, this does not of itself necessarily lead to reduced post-consumer
waste volumes. If it takes only 50g of material as opposed to
100g to produce a product weighing 20g, the consumer and WDA are
still faced with 20g, whereas the commercial sector has saved
50g.
At this point I would like to address the issue
of definitions. This is a matter of importance as a language is
emerging which varies significantly from the terms used in Making
Waste Work.
This issue was highlighted when reading the
evidence to and last report of this committee. Paragraph 198 states
that as a WDA makes waste disposal savings in respect of materials
recycled by a WCA "there would appear to be an incentive
upon a WCA to encourage householders . . . to recycle." This
might be true, but is unlikely. The WDA reimburses WCAs on the
basis of disposal savings whereas the WCA incurs collection costs
for recycling (including disposal of the material which should
have positive value). There is no economic model yet produced
which shows that these totally different services should have
the same unit cost. "True" waste minimisation represents
a reduction in the total waste handled by the WDA, and total saving,
whereas recycling credits (the reimbursement from WDAs to WCAs)
are a reward for disposing of something in a preferable environmental
way.
Neither is minimisation synonymous with diversion
from landfill. Indeed, it can be seen differently depending on
who is making the assessment:
Waste minimisation:
— To a WDA— reduction in the
amount of waste it handles under s51 of the EPA. Recycling is
not minimisation but a form of disposal.
— To a WCA— reduction in the
amount of waste it collects under s45.
WDAs provide civic amenity sites and, by way
of example, if a resident takes their household waste to one of
these sites (at which it might be recycled) it is not collected
by the WCA who therefore have no record of its existence. No waste
has been minimised in total. CA sites are not based on the catchment
areas of any single WCA and therefore it is true to say that which
WCAs can assist with minimisation, only the WDA knows what is
happening in total. Both have a power to promote waste minimisation
(a matter recommended by the committee) however, funding is unclear.
Another example of the confused thinking of
government in this matter applies to home composting. Until 1999
WCAs could provide residents with home compostors and could count
on assessed quantity of composting towards their recycling targets.
WCAs therefore could see a return on their investment and less
waste came into the waste stream, which pleased WDAs. Some WCAs
abused the assessment process, however, the principle was sound
even if practice created some problems.
Subsequently, government decided that home composting
would not count towards recycling levels. There is now no incentive.
The waste management realities remain, however, and any waste
not produced by a house eg disposed of on the property, is waste
minimisation. WDAs still benefit from this by virtue of less waste
but are prevented from incentivising their WCAs in financial terms.
In addition, WDAs do not have powers to provide this equipment
to residents.
The government's proposals in the strategy regarding
minimisation are unlikely to be as effective as they would wish
because of a lack of understanding of roles of authorities and
the barriers created by the existing financial system. Without
such an understanding, motivation is unlikely. Funding mechanisms
are unclear and potentially contradictory.
Surrey has overcome some of these structural
problems through its contract by placing the minimisation burden
on the contractor as a transfer of risk under the PFI structure
test. However, the future scale of PFI funding for waste, although
sizeable, will deny this opportunity to most WDAs.
When the Royal Commission on Local Government
(Redcliffe Maud) investigated the allocation of local government
functions it had a clear preference for unitary authorities. For
various reasons this did not translate into a universal application.
Nonetheless, unitary waste authorities, particularly London boroughs,
claim to perform better by virtue of being responsible for all
aspects of waste management. Something similar in shires might
be necessary, however, other measures can and should be tried
before this.
It is suggested that the committee consider
recommending to government:
(a) That WDAs have the primary waste minimisation
responsibility.
(b) That WDAs are provided with the power
to incentivise their WCAs financially.
(c) WCAs should be consulted as to whether
the financial incentives should include an option for their WDA
to charge them on a per tonne basis.
2.3 An increase in the recycling of waste,
particularly by greater development of markets for recycled material
The creation of WRAP is a positive move. However,
recycling is a global business, as recent experiences with paper
demonstrate. Congestion charging and improved public transport
is another chicken and egg example of the problems that WRAP will
face. The maintenance of balance as between supply (driven by
government targets) and demand, in the context of consumer confidence,
is difficult. In addition, we have a planning system which:
(a) require the shires to compile Waste Local
Plans but which excludes from their scope processing plant such
as glass factories, paper mills etc.
(b) in the context of economically-scaled
processing capacity should be set at regional level, and
(c) finally places the authority to approve
applications for such regional facilities with local district
councils' development control departments.
It will be difficult to make much headway in
a short time in such a context.
2.4 Increased use of incineration as a waste
disposal/recovery option—what would the implications of
this be.
Incineration is an alternative to landfill,
not recycling.
Government has danced around this issue, even
to the extent that its stance on incineration changed so dramatically
between the draft strategy and final version. This was a political
and not waste management decision. It is not invalid because of
this, however, their subsequent pronouncements render the government
duplicitous in some people's eyes.
The government's use of its derogation rights
under the landfill directive comes about only because we landfill
so much of our waste— 90 per cent plus of household waste.
Clearly there is a tension between the mathematical and waste
management realities and political needs. However, sustainable
waste management does not lend itself to short term expedient
political decision-making.
The government has indicated a major shift away
from incineration in the Waste Strategy and reinforced this by
excluding from the definition of recycling the re-use of incinerator
bottom ash, something that it specifically included in the previous
definition.
Surrey County Council took a bold step with
its contract that took its lead from the government's stance in
the draft strategy. It therefore took a science-based pragmatic
approach to waste management. It was guided by overwhelming private
sector views which were canvassed during the contracting process.
Consequently, it relies heavily on incineration. It is flexible.
However, the need to demonstrate this to such a degree so early
in its term has come as something of a surprise.
The concerns regarding incineration are real
and it would be foolish to underestimate them. Primarily they
fall into two distinct camps—air quality and traffic. Traffic
is a local factor and will be judged on a case by case basis.
Air quality is different. The government is again acting in a
contradictory fashion here.
It is government agencies which advise on and
set emission limits, and which grant pollution control authorisations.
However, they are not responsible for national waste management,
government is. While there has been a shift in the government's
stance on a political level and in the strategy, there is no evidence
that it is grasping the nettle of air quality with a view to promoting
a science-based approach to this. Essentially local authorities
will be gradually worn down if the hearts and minds issues are
not dealt with nationally.
As regards the implications of an increase in
incineration, it is felt that an increase should not necessarily
lead to the abandonment of recycling, as these can co-exist. If
necessary, WDAs can be given recycling and energy recovery ratios
to replace current recycling targets. It is felt unlikely that
the necessary increase to meet the landfill directive diversion
rates can be met within the current waste planning regime which
is in need of urgent review.
Referring again to the Royal Commission, one
of its aims was to deal with matters so as to take them off the
agenda for a considerable time. The issue of public confidence
regarding incineration needs to be faced, dealt with and taken
off the agenda for a considerable time.
2.5 A reduction in the amount of waste sent
to landfill
Currently some authorities are reporting increases
in waste of over 5 per cent p.a. Even if the national average
is 3 per cent the mathematical reality is that this growth will
not translate into a reduction in landfill even if the target
for 2004 (average of 17 per cent recycling nationally) is met.
This will occur, however, if the 2005 target is met. At the same
time there is a considerable body of opinion which suggests that
the 25 per cent level is unlikely to be achieved. Therefore in
the short term (four years) the best that can be hoped for is
a reduction in the rate of increase.
If a reduction could be achieved through waste
minimisation and recycling, this would be a great success. It
still leaves the waste reality that over 50 per cent of waste
remains to be dealt with by other means. There appears to be no
way of escaping this reality and the two options available: landfill
and incineration.
As regards the tax credits scheme (LFTCS), Surrey
is partnering with its main contractor, SITA, all districts and
other voluntary groups the creation of a fund to be disbursed
through the Sustainable Surrey Forum. This will have effect in
all project categories. The government has given a clear, strong
and welcome lead here regarding its preferred use of funds and
Surrey will take this on board. Surrey County Council, its WCAs
are currently recycling 17 per cent and would hope to drive this
upwards through partners. Significantly, some of the local government
barriers referred to earlier regarding waste minimisation and
incentivisation can be overcome by such partnerships using LFTCS
funds. The Forum will look to develop a medium term plan and in
this respect the recycling target dates of 2004 and 2005 do not
sit well with a guaranteed LFTCS period ending in 2004.
As regards the Forum, it has developed a range
of sustainability indicators, some of which involve waste. Whereas
government Performance Indicators tend to focus on the obvious,
others being looked at seek to challenge conventional wisdom.
One of these involves assessing waste management sustainability
by reference to emissions (CO2 etc) per tonne mile travelled by
waste. This naturally leads to an holistic approach which, for
example, challenges the need for civic amenity sites as WCAs are
able to collect all materials in a way which gives improved environmental
benefits. This will lead to cost benefit analysis of removing
these sites from the waste system (and two million + vehicle journeys
per annum by residents who use the sites) and whether in countrywide
environmental terms this is a better option than the current system.
The ability to reimburse WCAs would be necessary and has been
raised earlier as an issue.
Primarily, and rightly, LFTCS should fund capital
eg recycling boxes, vehicles etc. Surrey's contract enables the
primary revenue risk to be dealt with by the contractor. It is
understood that the possibility of using LFTCS for large-scale
capital assets eg processing plant etc has not been explored,
although LFTCS have been used for buildings in other project categories.
The need for logistical balance as between supply, processing
capacity and demand still remains. In light of the funding priorities
which the government has now set, the scheme's objects should
be reviewed to ensure that the development of large-scale assets
is possible for category c projects.
In addition, a clear steer regarding the continuation
of the scheme is necessary to enable coherent planning over the
medium term.
2.6 A reduction in and better management of
hazardous wastes
No evidence to submit here.
2.7 Significant action to improve the example
set by government in exercising "green" procurement
policies.
All responsible authorities, particularly public,
should endeavour to practise what they preach. This sends out
correct messages and gives leadership, particularly when others
are expected to make changes to their habits, lifestyle etc. This
can be seen as being a form of community leadership and is an
important role for government and local authorities. However,
in this context and it is not considered the key one. This remains
to properly assess, plan and put in place the necessary structure
to enable the delivery of outcomes through others.,
2.8 Sufficient action to educate the public
about the importance of sustainable waste management.
This is an interesting point. When the committee
last looked into this, one of its standard questions to witnesses
was "what is your understanding of sustainable waste management".
A range of answers was received. Witnesses who are experts in
the field of waste management agreed that there is no single definition.
In the context of this question, if they could not agree how could
this concept be delivered to the public in a way that leads to
beneficial changes in their behaviour.
Also in the report there was evidence to suggest
that the public were able to understand concepts and should not
be talked down to. The combination of these factors will lead
to interesting debate.
Surrey's approach is clear. The task is redefined
as "to inform the public about waste management issues of
direct relevance to them which they are in a position to affect
through their own actions". Clearly, we need to understand
the behavioural drivers of individuals if progress is to be made.
Evidence from various waste awareness campaigns shows some correlation
exists between effort taken to publicise the message and people's
recognition, but little between recognition and changes in habits.
If the aim is to change people's attitudes then an understanding
of how they think and act is crucial. In this context, Surrey
County Council is supporting the University of Surrey Environmental
Body in a project which it is conducting within Surrey using LFTCS
from SITA Environmental Trust. The project will engage with over
15,000 residents to attempt to establish their behavioural drivers.
These are unlikely to be totally Surrey-specific and therefore
the results should enable improved waste management planning both
in Surrey and elsewhere.
This issue of education is distinct from the
one raised earlier regarding the government informing the public
regarding incineration. That does not need a change in action,
simply an understanding and acceptance of what others want to
do. The two tasks can be linked, but they are different.
As regards the impact which the strategy will
have on educating the public, much of this lies directly with
WRAP. If they have sufficient funds then they can make some headway.
However, as mentioned above, waste management is essentially about
logistics: the balancing of expectation, supply, processing capacity
and demand. To raise people's expectations (convincing millions
to separate their recyclables) only to have these founder on the
local reality when their WCA has no kerbside service will be disastrous.
Local authorities are best placed to install the infrastructure
and ensure that the process flows.
WRAP will be best placed to articulate and lobby
on behalf of authorities and government. They might also consider
acting as a materials broker countrywide to ensure continuity
of markets (although this smacks of the discredited DSD system
which dumped, either on other countries or its own incinerators/landfill
sites, tonnes of unwanted recyclables). Co-ordination is essential,
as is understanding of the roles each party is best placed to
play—which is to revisit one of the first points made regarding
the government's apparent lack of understanding.
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